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MEMORANDUM

To: Greg Nizich, U.S. EPA, Office of Air Quality Planning and Standards

From: Colin Hayes and Jason Huckaby , Eastern Research Group, Inc.

Date: November 26

, 2007

Subject: Summary of October 30, 2007 Meeting Between EPA and The Vinyl

Ins titute to Discuss Remanded Polyvinyl Chloride and Copolymers Production (PVC) NESH AP Issues and Future Activities

On October 30, 2007, members of The Vinyl Institute (VI) met with EPA at EPA’s campus in Research Triangle Park, North Carolina. The attend ees and affiliation are

listed below:

Name Representing

Frank Borrelli The Vinyl Institute

Barry Christenso n Occidental Chemical Corporation

Ken Atkins Georgia Gulf Corporation

Mary Bachynsky Formosa Plastics Corporation

Peter de la Cruz Kelle r and Heckman (Attorney representing the Vinyl Institute)

Greg Nizich U.S. EPA OAQPS

Ken Hustvedt U.S. EPA OAQPS

Marcia Mia U.S. EPA OGC (attended via telephone)

Jason Huckaby Eastern Research Group , Inc.

Colin Hayes Eastern Research Group , Inc.2

The meeting began at 10:00 AM EDT, broke for lunch around 11:45 AM EDT, and reconvened from 1:00 PM to approximately 2:40 PM EDT. The summary of the meeting’s discussion follows.

Opening Remarks

Frank Borrelli (VI) touched on the following topics in opening up the meeting: Other VI members that were not present at the meeting included PolyOne, CertainTeed Corporation, and Westlake Chemical Corporation. Most PVC manufacturers produce PVC homopolymers, high volume suspension resins, and there is some em ulsion polymerization. Two major companies engaged in co

- polymer production are Dow Chemical and Noveon (both of these companies are not members of VI). Colorite is another PVC manufacturer that would be affected by the PVC

NESHAP. Colorite is not a VI me mber, but VI has contacts with them.

PVC is a 15

- 16 billion pound per year industry. The VI has been approached by NACAA. VI wants to make sure NACAA understands the PVC manufacturing process. VI does not want to do something inconsistent with what they are doing with EPA. VI wants to help develop a MACT that will not end up in the courts. VI plans to meet with NACAA again after meeting with EPA. VI wants to understand what data EPA needs and how best to get the information and data to EPA to support the rulemaking effort.

PVC Industry and Process Overview

Frank Borrelli and Mary Bachynsky gave a presentation on the PVC industry to provide background information to EPA regarding the industry, PVC resin types, and historical

and current PVC resin manufac turing practices. Topics presented and notes on the presentation follow: Dispersion resins versus suspension resins. Review of PVC polymerization chemistry. NESHAPS developed to control residual VCM. Review of PVC process.
Raw materials: VCM, water, surfa ctants, initiators, RVCM (from overhead recovery).

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- 12% VCM is typically unreacted. VCM recovery: incinerators, for vent stream combustion (includes air due to openings). Inert streams from reactors, initiators introduced; through to thermal oxidizers.

Ho mopolymer process: monomers into reactors typically 99% pure (“technical grade”).3 Change temperature in reactors: chain growth changes, chain growth termination, change molecular weight in process depending on end use requirements.
Suspension process : uses organic initiators; “grow” the polymers in organic phase.
Dispersion process : polymer “grows” in a water phase

– micelles, use surfactants (emulsion chemistry). Emulsion resins: particles size of small powdered sugar. Suspension resins: larger particle si zes. EPA asked whether surfactants and initiators pass through the process and are there HAP associated with those as they pass through the process? VI responded that there are some breakdown products and methanol that get attached to the PVC polymer chai n. However, these are probably small amounts; less than 1/10 of 1 percent. Methyl celluloses might have methanol (a HAP) as a solvent (commonly used) for suspending agents. PVAs (polyvinyl alcohols) also used. Peroxides use odorless mineral spirits, but nothing on the HAP side. Company practices vary however. Would probably use a few gallons of initiator in a 30,000 gallon reactor. Once VC is formed, not many other things formed. Low ppm level impurities in VCM (volatiles) that would carry along with

the vinyl chloride, vast majority would go back to recovery system;

thermal incinerator. Realistically, nothing is 100% pure. Once through the stripper, the slurry enters an “open” system. Stack out of dryer, what goes out the dryer side depends on permit limi ts and depending on resin being produced. Typical resins today, (polymer itself) down around 1 ppm RVCM (RVCM

– “after stripping loss”) RVCM no longer regulated by NESHAP past the strippers, but state permitting agencies have regulations that pick up here (centrifuges, dryers, these limits vary). State air toxics regulations, non

- attainment areas, etc. Texas, have to model emissions and meet ground level numbers. LA, Maryland, Texas

– risk based

standards.

There was a question by Greg Nizich regarding v inyl chloride (VC) in landfills and whether the VC came from PVC products in the landfills. The response from industry representatives was that the VC in landfills is a degradation product of TCE and perchloroethene (“Perc”). Industry representatives not ed that chlorinated solvents were previously placed in landfills, and the VC present is not residual VC from plastics production.

Two broad classifications of PVC resins

o Suspension

o Dispersion Resin subcategories are referred to as “grades.”4 Suspension: ge neral purpose: flexible and rigid

o Specialty

o Copolymer Ability to get RVCM down to a certain level depends on the type of resin being produced. It’s all PVC, but the resins are different and have different properties depending on end use. This sets the “s trippability” of the resin. 1999 data: 73% general purpose, suspension resin, rigid extrusion grade (RVCM levels can get very low in these). Homopolymer is vast majority of regulated production

– copolymer just a small

part. Amount of VCM remaining in wet PVC slurry is known as “residual VCM”

RVCM. Steam stripping is used as primary means in industry for controlling VCM

emissions. Each resin type has a predictable range of RVCM level after stripping. Dispersion resins are more difficult to strip than other PVC resins. Many states have more stringent limits, but not based on daily limits, less frequent demonstration basis. This allows flexibility. Frank: daily number is critical for the industry. For flexibility for the industry, daily numbers need flexibil ity Many facilities have quarterly or annual limits in the permits. Daily limits may be no problem for facilities that made the same type of resin all the time. Other facilities change resin types in processing, so quarterly/annual averages allow

flexibi lity for these changes depending on customer demand. Striping is used consistently around the world. Industry performance is improving. What defines RVCM limits: variations in raw material purity, operating conditions and equipment, stripping conditions r elating to product quality, requirement to be able to comply with a daily limit, production of different PVC grades. EPA inquired as to whether there is a difference in the stripping process itself (e.g., the column itself, trays, steam rates, etc.) that w ould affect the levels of residual vinyl chloride? An industry representative responded that for certain resins, one cannot just increase the steam flow. Some resins will degrade, change color, etc. VI stated that not every company can operate the same w ay. Each company has an established technology practice. General purpose suspension resins have a higher porosity and are easier to strip. Emulsion resins are generally harder to strip. VC copolymers Most VI members do not make copolymers Vinyl acetate ( 10

- 40%) goes into reactor (substituting VCM for VA) Properties similar to flex PVC, floor tile, can coatings PVDC, copolymers with VC: saran, copolymer with acrylates Very small in comparison to total market5 Difficult to put an emulsion resin through a col umn, use batch stripping and

smaller reactors

Conclusions: BACT for PVC resin is steam stripping Daily RVCM limits should be set high enough [to allow for differences in resins being produced?] Copolymers are more difficult to strip.

This concluded the pr esentation by The Vinyl Institute.

VI wants to move forward with the MACT, but would like some flexibility and retain the ability to be competitive and satisfy a very broad marketplace. VI asked EPA where this exercise is starting (e.g., with respect to a ddressing surrogacy issues) and reminded the group that other procedural items raised. EPA stated its desire to be more thorough with respect to setting floors, CAA requires review of Part 61 NESHAPS? Issues the courts raised, “Brick” decision. Try to ge t as much info, but not duplicate information. Get info from permits, facilities, fill in data gaps. Want to do best analysis possible for the emission points...what’s the best out there, set floors. Re: timing: Industry asked if EPA hoping to get two bi rds with NESHAP review and vacatur of PVC standard? EPA acknowledged that is the intent. EPA stated that it is possible that nothing will change (from the remanded PVC standard), EPA may just better explain its process and reasoning. VI suggested that the y perhaps needed to get copolymer producers into the

discussion. Industry noted that a lot of emissions that we see (reported in NEI) are combustion byproducts. EPA requested a copy of the presentation given at the meeting by VI. VI agreed to that

request

.

Emissions Information and Data Needed to Address Remand

The post

- lunch session was less structured than the morning presentation, and consisted of discussion on the emissions data that EPA currently had for affected PVC facilities,

additional data nee ded to address the remand, and how best to obtain such additional

data. VI inquired as to whether EPA is interested in obtaining test data, calculated data, or something else. EPA responded that test data would be preferred.

VI noted that other HAPs besid es VCM would only be present due to small amounts

of additives to the reactors. Regarding the presumably small amount of HAP carried through the manufacturing process, VI wanted to know if there was a threshold level cutoff, such as a de

minimis level, or a certain ppm level where a compound might be classified as a

“non

- detect” or “less than X ppm.” EPA responded that there is no such level or guidance set for threshold or de minimis levels.6

VI reiterated that for compounds other than VC and HCl (combusti on byproduct), any HAP will probably be present in additives, but would be present in very small amounts. Additionally, the additives themselves are added to reactors in very small amounts already. It might be difficult to quantify the levels entering th e system at the reactors. The only source of HAP information from reactor additives would be MSDS sheets, but if the HAP is below a certain level, it is not required to be reported on the MSDS. If it is, it would be in the ppm range and very small.

There was some discussion of emission units and emission points in the PVC manufacturing process and what is currently controlled.

o VI stated that reactor opening losses (ROLs) were part of the original NESHAP. Added that reactors are closed systems and compani es have to put in controls to make sure there are no uncontrolled reactions. ROLs probably constitute less than 1% of total VC emissions.

o Suspension resins can run several batches between reactor openings

o Reactors producing dispersion resins are typically opened between every

batch

o VC storage spheres are pressurized and contained.

o VI: fugitive emissions are regulated and controlled, there are OSHA standards for worker exposures

o Vents for recovery are controlled

o VI: there is HCl control, scrubbers, also tr y to avoid burning VC; good evacuations of equipment PVC transfers from reactors take place through a variety of methods, including pressure transfers and pump

- outs. All transfers from reactors are closed and

contained. Some plants have dedicated strippin g trains for a single product. Water is used to clean reactors, organic solvents would probably not be used (e.g., methanol) VI inquired as to whether process flow diagrams showing inputs, outputs, where everything is going in the process would be useful t o EPA. EPA agreed. Occidental Chemical inquired as to what information is still available from the last time around (PVC rulemaking)? ERG directed the group to the PVC docket available on the “regulations.gov” website, and noted that there is a lot of

in formation there regarding compounding processes. VI noted that compounding might typically be collocated with a PVC resin manufacturing process and this fact might cause certain compounds to show up in a facility’s emissions data, such as NEI data.

The att orney for VI stated that there was not much environmental group participation in the initial rulemaking. He added that it is hard to tell from the NEI data the source of compounds that may appear in the process. Need to figure out a way to

address “what’ s not there” instead of “what’s there” VI noted that process flow sheets are very facility specific and wanted to know if EPA would prefer a generic process flow sheet, or several flow sheets specific to each facility?7

An industry representative noted that low level of HAP that would be present for small tanks and other equipment with vents, storage tanks, combustion emissions, and for natural gas combustion on a dryer. Industry questioned whether t hese types of emissions would be covered under the affecte d PVC source or not. An industry representative inquired as to what fits (with respect to compounds) with the surrogacy issue, and how would other compounds be addressed (those for which, if any, VCM may not be an appropriate surrogate)? The attorney for VI inquired as to whether EPA currently has a guideline document or established procedure for determining surrogacy? EPA responded that it is uncertain if such specific guidance exists. Industry representative noted that VA (vinyl alcohol) storage tanks a re regulated under organic liquids distribution MACT. There may be regulatory overlap questions and issues, and multiple MACTs may apply to a particular plant/process. Industry also noted that some PVC plants send streams to an EDC plant that is covered under the HON, so a compound such as HCl would be covered (under HON), even though not explicitly by a PVC standard. Industry representative asked where the circle drawn around a PVC plant for applicability? Some equipment, such as incinerators are not in tegral to the PVC manufacturing process. Suggested that industry could formulate a diagram showing what equipment connected to a PVC plant is covered by which regulation(s). ERG inquired as to whether CISWI would apply. Industry responded that they did

n ot think so. Industry noted that continuous monitoring in stacks for VCM is required. The attorney for VI noted that the discussion seemed to be heading towards industry providing EPA with a detailed diagram of the PVC process? EPA and industry

representa tives agreed. Industry reps also suggested that they could provide a better description of additives and associated HAP entering the process with reactor additives. EPA requested clarification that there is not other point in the PVC process where

material s or chemicals are added other than the reactor and the compounding area (if present). VI confirmed that this is the case. Industry noted that a flow diagram would probably best help EPA and that the NEI data would not be very useful. The attorney for VI stated that industry and EPA may have to “cast a little broader mental net” to make sure everything (in the PVC process) is covered. Industry noted that the PVC process is actually a narrower set of process/equipment than what the petitioners might be used to seeing. The VI requested the list of HAP identified by petitioners. EPA agreed to get that list to the VI and concurrently requested a copy of the presentation made by VI at today’s meeting. Industry noted that some plant data may be under a records r etention policy and thus

would either not be available or verifiable. Industry inquired as to whether permit data be helpful. EPA did not believe that permit data can be used to set limits.8

VI stated that flow sheets, product specifications, perhaps some fate analysis might be

useful. The attorney for VI stated that VI would prefer to just work with EPA for the time being, then get back with NACAA. EPA noted a footnote in the VI’s letter to EPA, dated October 12, 2007 from Peter de la Cruz to Greg Nizich, referencing footnote number 19 in the letter stating that there are/were three plants that are pursuing or have performed a MACT analysis under CAA Section 112(j) and wanted to know how the analysis was or is being performed. Industry representative noted that they just started that 112(j) process and that they are not determining new emission limits, just going through the mechanism. EPA stated that it thought this can be best controlled similar source but not necessarily in same industry. VI inquired as t o EPAs timing for completing the PVC rulemaking process. EPA stated that it would like to “rough” something out, see how it looks, then go from

there. VI noted that it needed to get more VI member companies involved in this process,

and asked if it would be acceptable to get information to EPA in the next 30

- 60 days. EPA agreed that timing would be acceptable. Industry wanted to clarify that what EPA is looking for from them is a specific PVC process diagram. EPA agreed, and added that it would like ever ything labeled, with all of the emission points captured and what is being emitted from each point in the process. VI noted that this would be an iterative process, with information reviewed by all VI

members. ERG asked industry representatives whether any facilities are missing from the list EPA provided to VI?

o Industry noted the exclusion of OxyChem, Pasadena, TX

o Also noted that the OxyChem Deer Park PVC plant sends waste to its La Porte EDC/VCM plant. The La Porte EDC/VCM plant should be

combined with t he Deer Park plant. Georgia Gulf confirmed that all of their facilities were represented on the EPA list. Formosa Plastics and Georgia Gulf noted that Geismar Vinyls is now Westlake. The VI extended their appreciation for the time to meet with EPA.

The mee ting concluded at 2:40 PM (EST).